MFA submitted a comment letter to SIFMA in connection with a proposal put forth by SIFMA for an “Optional Mini-Closeout Provision” Annex to the Master Repurchase Agreement (MRA). The Annex would give a non-defaulting party in a repo transaction an optional mini-closeout remedy in the event of a failed securities delivery. The Annex would also permit a non-failing party to margin a failure to deliver if it does not exercise its closeout remedy. MFA’s comment letter proposes that the template MRA (not an annex) should force parties to use the mini-closeout remedy, thus, making the mini-closeout process a standard term of the MRA in all repo transactions. A copy of MFA’s mark-up to the Annex can be viewed here.